Compliance - Refund Management - BankMobile Disbursements
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Compliance

Compliance In A Dynamic Environment

For 17 years, our Refund Management® service has been trusted by colleges and universities around the nation to disburse billions of dollars in federal aid to students. We have decades of combined experience in managing the unique intersection of Department of Education Cash Management guidelines and federal banking regulations. BankMobile Disbursements (part of Customers Bank), provides a compliant, full-service solution for institutions and students. We have a vigilant Government, Regulatory and Compliance team in place to ensure we meet or exceed regulations in this dynamic environment.

 

New Department of Education regulations governing Title IV disbursements on your campus went into effect on July 1, 2016. As the industry leader, we helped to shape these new policies which were developed over the course of several years.

  • July 1, 2017 – Implementation of the Dept. of Ed’s account fee disclosure format
  • September 1, 2017 – Disclosure of monetary and non-monetary, payments or receivables by the parties under the terms of the contract
  • September 1, 2017 – Disclosure of the number of students who had financial accounts under the contract at any time during the most recently completed award year, and the mean and median of the actual costs incurred by those account holders.

 

BankMobile Disbursements manages all of the above requirements on behalf of your institution. Our internal and external Government Relations teams regularly track all movements in regulations and legislation and we have proven we are able to navigate changing environments. We believe a relationship with BankMobile Disbursements is advantageous to you and your students in the future, as it has been for many institutions, as is evidenced by our current offering which affords all the protections brought by the new Department of Education’s rules.

COST MITIGATION
We are witness to our clients’ struggles with rising costs and the impact to the Business Office.

 

BankMobile Disbursement’s Refund Management service:

 

  • Alleviates the costs of tackling compliance on your own
  • Reduces the risks associated with collecting and storing student bank account information on your institution’s servers
  • Handles all exceptions
A BETTER STUDENT EXPERIENCE
We handle all student refunds on behalf of your institution—regardless of the disbursement method students choose.

 

Every student will experience:

 

  • A clear, neutral and transparent on-line process for selecting how to receive refunds.
  • Fast, reliable and secure access to funds.
  • A choice in how they receive their refund, always free of cost. Choices include deposit to another account or electronic deposit to a BankMobile Vibe account.
  • Optional text alerts on the status of their refunds, regardless of how they receive them.
  • Customer service telephone line (7 days a week), on-line FAQs, email and social media.

 

BankMobile Vibe, a digital-only, FDIC insured non-interest bearing checking account designed specifically for students. Vibe has no monthly fee for students, no overdraft or NSF fees, no PIN fees, no teller withdrawal fee and no minimum balance requirements. Click here to view our fee schedule.

Vibe
  • Is open to students regardless of financial history
  • Offers strong protections put in place by the Department of Education
  • Is low cost; simple fee schedule
  • Has fee-free access to 55,000 Allpoint® ATMs
  • Has no offers of credit or overdraft protection
  • Is not a prepaid card
  • Has sophisticated but easy-to-use budgeting tools
Vibe helps students look to the future by:
  • Coaching students to move to financial independence
  • Promoting skills for building a strong credit score after leaving college
  • Aiding forward thinking about finances and savings
  • Encouraging graduates to pay off their student loans
  • Helping account holders make a good life for themselves

Even the most streamlined in-house electronic refund programs still require check distribution, the costs of which add up quickly. College business officers and CFOs that we serve have shared that the cost of paper checks continue to rise, including printing and mailing, but also return check fees, canceled check fees and exception handling. By leveraging our full-service solution and leaving the student service to us, your institution can drive significant savings that can be reinvested in higher impact initiatives on campus.

If you are a current client and would like more information, you can consult the comprehensive Compliance Handbook provided to you by BankMobile Disbursements or contact your Relationship Manager.

If you are new to BankMobile Disbursements, we would be pleased to discuss your compliance concerns or questions.

 

 

Please contact:

Andrew Rakaczki VP of Government Relations

arakaczki@bankmobile.com

(203) 776 7776 x 4128

FAQs
Isn't it less expensive to build an ACH program ourselves or run an ACH-only program? What would that mean for my institution?

While it is true that the act of initiating ACH transactions is inexpensive, there is much more to consider when running a refund program, including non-ACH refunds and student communications and service. By building your own program, your institution may take on the considerable security risk of housing banking information and PII (Personally Identifiable Information) on internal servers. You may want to consult your IT department about the cost and risk to your institution of protecting this data so you can factor this into the evaluation. Also consider that it would be very difficult for an institution to achieve 100% ACH participation. That is, some students may not or cannot deposit their refund electronically and will require a paper check. In many cases, the in-house processes of printing checks, reporting, and student service along with exception handling (like managing returned mail) can be very costly and add up to much more than the full cost of our solution. Our Refund Management® Service was built to provide:

 

  • Full-service call centers for both students and administrators, moving most (if not all) of the operational and service burden off of the institution
  • All communications to students, including but not limited to refund preference selection, direct payment notification, exception handling and reporting
What are the differences between Tier 1 and Tier 2 providers?

If a third-party servicer offers a financial account as part of its disbursement service, a Tier 1 arrangement exists. Our disbursement service is a Tier 1 service. If a financial institution offers  branded access device (such as a card), offers a joint ID and bank card, or the institution markets a financial account directly to its student one of these conditions must exist), AND at least one Title I credit balance ends up in that account, a Tier 2 arrangement exists. This chart from NACUBO can provide a more detailed view.

What advantages does having a Tier 1 relationship bring to institutions and students?

We believe the main advantages of Tier 1 relationships include:

 

  1. Protection from potentially high-interest credit products:
    • Tier 1 service providers are precluded from offering credit products to your students. In other words, with a Tier 1 service provider, there is no risk that your students will receive unsolicited offers for credit products such as credit cards.
    • Tier 2 service providers and any other non-Tier 1 relationships are not subject to this provision, so your students may not be protected against being targeted for potentially high-interest credit products.
  2. Transparency and protection from fees:
    • Regulations require a clear, fact-based and neutral selection process that students must go through to select a refund preference.
    • In addition, the Department of Education has regulated the types of fees that Tier 1 providers can charge on accounts offered within the selection process.
    • All of these protections do not apply in Tier 2 or other non-Tier 1 relationships.
What is student consent required for and when?
  • The new regulations state, per § 668.164(e)(2)(i) – students must consent to opening a financial account before an access device (or card) is sent to them, with an exception if the card serves an institutional purpose (such as an ID, library or meal card).
  • Per §668.164(e)(2)(ii)(A)(1)-(4) & § 668.164(e)(2)(ii)(B)– institutions may transmit information necessary to process refunds to third-party servicers, including directory information (as defined here,) as well as student identifier, the disbursement amount, and a shared secret. No consent is required, and the only change from our existing demographic file process is that SSN may no longer be transmitted.
  • Higher One always has required student consent before opening an account. We have never opened an account on behalf of a student without their consent and we will never do so.
  • In addition, we have never required students to open a checking account in order to receive their refunds. Students have had and will continue to have choices in how they want to receive their refunds and are never charged a fee to receive their refunds.
  • With the exception of those with ID programs, we will discontinue the mailing of non-active cards in the Refund Selection Kit to students by July 1. We will continue to send a Personal Code in the mailed Refund Selection Kit, as we do today, for students to validate their identity. No consent is required to send demographic information to third-party servicers or to send the Personal Code.
What changes will take place with my relationship team when the Customers Bank acquisition is completed? Who will be my point of contact with the new company?

We are pleased to say that our entire Relationship Management, Admin Support and Call Center teams will continue to serve you and your needs after the acquisition, with a goal of minimal disruption to day-to-day operations.

Are the timelines and process of wiring funds going to change with the new regulations?

No, specifically there will be no change to:

 

  • The process of sending demographic files (with the exception of no longer being able to send SSNs in whole or in part)
  • The refund file and wire process
  • Disbursement timelines (the 14 day rule)
  • Our model of personal service
Which new requirement will mean the biggest change for my institution?

Likely the biggest change you’ll see in the short term is the requirement to make available our contracts as well as account fee information specific to your institution on your website by a 9/1/16 deadline date. We are making that easy by providing you with a link you can simply post. We will take care of ensuring that all of the necessary documentation and disclosures are posted and updated. Please look for the link to be available shortly on bankmobileadminsupport.com. This requirement applies to all Tier 1 and Tier 2 relationships. If your institution has a Tier 2 relationship and/or both a Tier 1 and Tier 2 relationship, all agreements and subsequent fee information for all relationships must be posted on your website.

How do the new regulations impact my students?

The majority of changes that are taking place are great for students, starting with the new online refund selection process, which will be simpler, quicker and easier to navigate. Working with a Tier 1 provider means that the financial account offered abides by strong regulations put in place by the Department of Education. Some of these regulations that are meant to protect students do not apply to accounts provided by Tier 2 providers or accounts provided in the open marketplace, including the prohibition of a point-of-sale or PIN fee, fees for in-network balance inquiries, and the offering of credit cards and debt products to students. Our disbursement service guarantees that an FDIC-insured checking account with all the consumer protections afforded by a Tier 1 arrangement is available as a choice for your students – regardless of their credit history. In addition, you can rely upon us as a chartered bank to be a single partner that provides both the disbursement service and the financial account for your students. We look forward to discussing our account offering in more detail on the webinars scheduled for early April.

What is the fee structure of the new account?

The new account offering is one of the most student-friendly accounts on the market. The new account will have no monthly fee for students, no inactivity fee, no overdraft fees, no point-of-sale/PIN fees, no teller withdrawal fees, no check ordering fees, and no fee to talk to a customer service agent. In fact the account will only carry three fees for students:

 

  • $2.50 for using an out-of-network ATM (outside of the new network of 55,000 ATMs)
  • $25 for a wire transfer
  • $10 to replace a bank card ($0 for ID programs)
What is your new ATM structure?

We are pleased to be able to expand access for accountholders to a nationwide network of 43,000 Allpoint® (55,000 ATMs internationally). Accountholders will have fee-free access to cash in this network. With this move to offer anywhere access, we will no longer be maintaining a specialized fleet of college campus ATMs. However, there may be opportunity for some campuses to manage their own ATMs on campus outside of this program. Your Relationship Manager can provide you with contact information and details.

What will happen to students who currently have the OneAccount?

The OneAccount will continue to be serviced by BankMobile Disbursements at this time.

How are you communicating these changes to students?

We have already begun communicating these exciting changes to our accountholders and will regularly communicate changes and enhancements going forward. Scheduled communications to accountholders will include advance email notification discussing when Allpoint ATMs will be available for use and when multiple fees will be dropped from the account. We will work closely with you as well, to provide all the education necessary for your student population by way of campus posters, signage and online materials. New material is already available today on our Storefront. Just customize and download based on your campus needs.

Is Customers Bank committed to Higher Ed and the student refund service?

Yes. Customers Bank has worked very closely with Higher One for more than two years as a bank partner, and is highly knowledgeable about our current business processes and campus needs. This move can ensure our leadership and team will continue to contribute their expertise and deliver a full-service product and personal service to you and your students under a new name. Customers Bank shares Higher One’s passion to serve college students and the millennial generation through technology. Higher One first leveraged technology to change antiquated processes to meet the needs of campus communities nationwide. Customers Bank’s BankMobile division has a vision for the future of banking that includes making banking more accessible and affordable to all. We believe combining visions, expertise and financial strength can help deliver next-generation services to you and your students today and tomorrow.

Want to learn more about BankMobile Disbursements?

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